KZ [KONGZHONG] CORRESP: February 18, 2011 Via Facsimile and EDGAR Assistant
[February 18, 2011 Via Facsimile and EDGAR Assistant Director Division of Corporation Finance 100 F Street, N.E. Re: KongZhong Corporation Annual Report on Form 20-F for the Fiscal Year ended December 31, 2009 filed on June 4, 2010 (File No. 000-50826) Dear Mr. Spirgel: For your convenience, the Company has included the Staff’s comments in this response letter in italicized]